EFRAG, the technical advisor to the European Commission in relation to the development of European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD), has published its Sustainability Reporting Work Programme for 2024. Points of note include:
Q&A: In mid-October 2023, EFRAG will launch an ESRS implementation Q&A process through a centralised access point. The Q&As will be published by EFRAG on a quarterly basis.
Implementation Guidelines (IG): EFRAG is currently working on draft IG on materiality assessment and value chain which it expects to issue for public consultation before the end of 2023. During 2024, EFRAG intends to publish further IG stemming from issues raised in the Q&A and relating to disclosure requirements in topical standards.
ESRS for Listed SMEs: EFRAG intends to issue an exposure draft of simplified ESRS for listed SMEs, small and non-complex banks and captive insurance and reinsurance undertakings in January 2024 which will be subject to a four-month public consultation.
Voluntary Reporting Standards: EFRAG is also developing a simple, voluntary reporting standard for use by non-listed SMEs to enable them to respond to requests for sustainability information e.g. where they form part of the value chain of an in-scope reporting entity. An exposure draft of the standard will be issued in Q1 2024 and will be subject to a four-month public consultation.
ESRS XBRL Taxonomy: EFRAG is developing a draft XBRL taxonomy for the ESRS and Article 8 of the Taxonomy Regulation which will allow reported information to be tagged in accordance with the ESRS and will complement the creation of the European Single Access Point (ESAP). EFRAG intends to issue the XBRL taxonomy for the ESRS adopted in July in Q1 2024.
Sector-Specific ESRS: EFRAG will start work on standards relating to the so-called "high-impact" sectors and banking, insurance and capital markets sectors in Q4 2023. EFRAG intends to issue draft ESRS for two "high-impact" sectors – (1) oil and gas; and (2) mining, quarrying and coal, together with the general approach to sector ESRS and the ESRS sector classification approach, in H1 2024. Under the CSRD, sector-specific ESRS are due to be adopted in June 2024 however EFRAG anticipates that this deadline will be extended by two years.
ESRS for Non-EU Companies: ESRS for EU branches or subsidiaries of non-EU companies that generate a net turnover of over €150 million in the EU (which are due to publish sustainability-related information from 1 January 2028) were due to be adopted by June 2024 however EFRAG notes that it is proposed that this deadline be extended by two years. EFRAG intends to consult on an exposure draft of these ESRS in Q4 2024/Q1 2025.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.